Hello all, I apologize for the two e-mails in one day but I figured this one was worth it. Over the past week I have had a few notifications from my contacts within the industry about incoming price changes.
First, before we get into what these changes are I want to take a look at why they are occurring. A few years back there was a suit filed with the International Trade Commission. This suit claimed that refrigerants from China were being dumped into the United States market at unfair prices. This dumping caused the prices on the most common HFC refrigerants to sink lower and lower.
In 2016 the Trade Commission ruled in favor of tariffs on imported HFC refrigerant blends from China (Two-hundred and ten percent tariff. The problem here though was that the Trade Commission’s ruling was on on HFC blends and not their components. That meant if you imported R-410A into the United States from China you would face a two-hundred and ten percent tariff, but if you imported R-125 and R-32 from China and then blended them within the US then you could work around the tariffs.
Obviously, this was a big hole. With this ruling there was going to be very little impact on HFC blend pricing. Sure, there is the extra cost of having to blend the product, but it is minimal when compared to purchasing competing product. The low priced product from China continued to flow freely.
The New Case
Everyone knew that the anti-dumping tariff had to be put in place on the components of blended refrigerants as well. But, in order to justify a new case with the Trade Commission it had to be proven that the tariffs instigated in 2016 were not effective and that companies were navigating around them by importing component refrigerants. From what I have read there needs to be at least a couple years of data in order for a case to move forward and be legitimized.
Well folks, here we are in 2019 and years have passed since the initial anti-dumping tariffs were passed. It is now time for a new case with the International Trade Commission. Yes, on April 4th, 2019 the American HFC Coalition and it’s members filed a new anti-dumping case with the Trade Commission. An excerpt can be seen below:
Section 781(a) of the Act is designed to address circumvention of an order by imports of out-of-scope merchandise, such as HFC components, that are completed or assembled in the United States after importation. As described below, the statutory criterion for initiating an anticircumvention inquiry are satisfied in this case. Evidence establishes that iGas USA, Inc., and its affiliate BMP USA, Inc., are mixing HFC blends in the United States using HFC components imported from China.
The process of blending HFC components from China into in-scope HFC blends adds only [ ] per kilogram of the finished HFC blend. As such, the blending performed by iGas and BMP is “minor or insignificant” within the meaning of section781(a)(1)(C) and 781(a)(2) of the Act. Additionally, the imported R-32, R-125, or R-143a, as the primary inputs of HFC blends, account for a “significant portion” of the total value of the merchandise within the meaning of section 781(a)(1)(D) of the Act. For these reasons, HFC components imported from China by TTI, Lianzhou, iGas and BMP are circumventing the antidumping duty order on HFC blends. Consequently, these components should be included within the antidumping duty order on HFC Blends from China pursuant to Section 781(a) of the Act.
As you can see, they have referenced companies bringing in HFC components from China and then mixing them in house to create R-410A, R-404A, and other popular HFC blends. Here is where things get a bit different though folks. Most people within the industry knew that this was coming. They had expected it to hit this year even, but what’s different is that the expected case was to be on the component refrigerants coming in from China. This new case though aims at the actual blending process. If you import HFC components into the United States from China and you then use those components to create a refrigerant blend that has a tariff then that tariff will apply to your newly blended refrigerant. In other words, you will be charged the tariff on R-410A even though you didn’t actually import R-410A. (You imported R-125 and R-32 instead.) An excerpt from the case is below as well:
COMMERCE SHOULD INCLUDE HFC COMPONENTS, “COMPLETED OR ASSEMBLED” IN THE
UNITED STATES INTO HFC BLENDS, WITHIN THE SCOPE OF THE ANTIDUMPING ORDER
PURSUANT TO SECTION 781(A) OF THE ACT.
All of this is preliminary. There is nothing official yet. The Trade Commission hasn’t even decided if they are going to investigate the matter. Their decision is expected to come towards the end of May. If the Commission does decide to investigate this case then we may have to wait a year, or more, to find out what the results are and if they will be levying a tariff on the blending of HFC refrigerants. Here’s the kicker though folks, if they do accept this case and rule in favor of a tariff a year down the road they could also make the decision to retroactively enact the tariff on blending refrigerants. That means that from the moment they accept the case up until their ruling refrigerant distributors could have to pay the new tariffs on their blended refrigerants… even on product that have already been sold. This is a worst case scenario, but if it does happen a lot of companies will have to write off these tariffs on product that they sold a year ago.
Price & Availability
As a direct result of the scenario above we have begun to see chaos in the HFC pricing and availability market here in the United States. In just a few days after the announced case two major refrigerant manufacturers sent notifications that they would no longer be accepting HFC refrigerant orders. Think about that for a second, two out of the four major manufacturers are no longer accepting orders. (I won’t name names here, but I’m sure you can make a good guess.) These companies put a hold on their distributing refrigerant because everyone is buying as much refrigerants as they can as soon as they can. Everyone is trying to beat that May deadline when the Trade Commission decides rather to pick up the case or not. That date is critical because, as we discussed before, if they do decide to investigate then ANY product brought in after that date could be subject to an anti-dumping tariff.
Along with the two manufacturers who are no longer taking orders I have another mailer from a third global manufacturer. While this mailer isn’t stopping orders it is announcing a large price increase on all of their HFC refrigerants. This company announced an increase of eighty cents a pound on their various HFC refrigerants such as: R-410A, R-407A, R-407C, R-404A, and R-507. For some reason, R-134a was also mentioned as having an increase although theirs was smaller at sixty cents more per pound. Having R-134a in here is strange since it is not a blended refrigerant, but this may have been thrown in there just because.
Based off of the increases mentioned above let’s take a look at one of the most popular refrigerants and how they are impacted. Remember, that these prices are always ball park and can change at any time:
R-410A – Twenty-Five Pound Cylinder Pricing:
- Fall 2017 – $140
- Fall 2018 – $65
- Jan 2019 – $68
- Feb 2019 – $56
- Mar 2019 – $49
- Apr 2019 – $100
R-404A – Twenty-Four Pound Cylinder Pricing:
- Fall 2017 – $175
- Fall 2018 – $80
- Jan 2019 – $70
- Feb 2019 – $58
- Mar 2019 – $50
- Apr 2019 – $105
These two pricing trends above really tell the story on what has happened over the past week or so. The prices on these HFC blends have nearly doubled. ALL of this is due to speculation and rumor as to what the Trade Commission will decide. Will they take up the case? Or, will they hold off?
Also, another point that I didn’t mention is that it’s not just the larger global manufacturers that are having a run on their HFC inventory. The Chinese are seeing huge trailerload orders placed as a last ditch effort to get as much product on hand as possible before a possible tariff begins. If this keeps up there very well may be a global shortage of R-125 again similar to what we saw in the spring of 2017. (At some points during that year we saw 410A and 404A prices upwards of four-hundred dollars.)
The only good news I can offer here is that once the May deadline approaches things began to slow down. Right now it is the uncertainty that is driving the market mad. At least once a decision is made everyone can sleep a bit easier.